StopSO UK is the Specialist Treatment Organisation for Perpetrators and Survivors of Sexual Offending. StopSO is also a is a child protection charity. StopSO work therapeutically with those who have offended, who are at risk of turning thought into action, with survivors and family members.

‘Safeguarding is everyone’s responsibility’

StopSO receives enquiries from individuals and organisations in respect of persons seeking therapeutic support. This includes individuals who have engaged in risky or harmful sexual behaviours and those who have inappropriate, risky or harmful thoughts in respect of sexualised behaviours. StopSO members also work with survivors of sexual violence, partners and families.

StopSO does not provide any therapeutic services directly. StopSO have a UK-wide independent network of suitably qualified and experienced professionals who are willing and trained to work with relevant individuals and their families. These professionals are supervised and include therapists, counsellors, psychologists, psychotherapists and doctors.

Safeguarding is at the heart of all we do. Everyone working for or with StopSO should be aware of this policy. The purpose of the policy is to reduce harm, keep everyone safe, and support members in the delivery of their services.

This policy should be read in conjunction with the Child Protection Policy and Disclosure Policy where applicable.

2.0 Definitions

For the purposes of this document:

a child is defined as someone under 18 years of
a vulnerable adult is defined as someone who is over 18 years of age and is getting, or may need, help and services to live in the community. StopSO recognises that the term ‘vulnerable adult’ has a variety of different legal meanings and maybe understood differently in different contexts. StopSO takes a broad and inclusive approach, and makes no material distinction between ‘vulnerable adults’, ‘adults at risk’ or other semantics. The vast majority of adults working with StopSO therapists may be vulnerable or at risk in some respect given the nature of the therapeutic support. The vulnerability of the adult at risk is related to how they are able to make and exercise their own informed choices but also to engage in preventative work if displaying harmful sexual behaviours. Also, to protect themselves from abuse, neglect and exploitation.
‘StopSO people’ or ‘StopSO person’ means those who work for StopSO, including employees, members, trustees, and board
‘Therapist’ is used as a catch-all term to include anyone delivering therapeutic or intervention services to individuals. It includes therapists, counsellors, psychotherapists, doctors, psychiatrists, psychologists, and any other similar label or designation. No weight or meaning is ascribed to the use of the word therapist over any
‘Member’ means a professional with a current StopSO membership. This will generally be a therapist.
‘DSL’ means Designated Safeguarding Lead. StopSO uses a process involving 3 DSL’s and the chair of the board of References to ‘DSL’ are therefore a reference to this process.

3.0 Awareness of Safeguarding Concerns

StopSO may become aware of safeguarding concerns through a variety of processes:

The referral to StopSO may itself raise safeguarding concerns
StopSO may be made aware of safeguarding concerns through another organisation
A StopSO member working with a client may raise a safeguarding concern with a StopSO DSL or other StopSO

4.0 StopSO Commitment

StopSO people and members will always seek to ensure that any therapy provided is safe and all reasonable safeguarding measures are considered.

Safeguarding is the responsibility of everyone, all the time. Safeguarding concerns may arise in respect of clients, other children or vulnerable adults, or of members and StopSO people. StopSO do not stand by when they can help.

The work of StopSO and its members means they encounter highly sensitive information routinely. Client confidentiality and privacy is of the utmost importance, as is the inherent trust and respect in the therapeutic relationship. These pivotal values are entirely consistent with powerful, proactive safeguarding behaviours because effective support and intervention is founded on harm reduction and safety.

StopSO occasionally received requests for safeguarding advice from other organisations. Assisting with such requests for advisory assistance are consistent with StopSO’s charitable objectives. Such assistance will not typically involve taking responsibility for actioning safeguarding concerns, but each case will be considered individually.

Most requests for therapy are received via an online form. The StopSO person handling the request will consider any safeguarding issues arising on the face of the information provided and will raise any concerns with the DSL, before making a referral to a member where appropriate. It is the experience of StopSO that many of the more significant safeguarding concerns arise in this way at this point, with StopSO people working to the instruction: If something doesn’t feel right, raise a concern.

StopSo may be made aware of a safeguarding concern from a member arising from their ongoing therapeutic process. Information may come directly to the DSL. If information comes to another StopSO person, the information must be passed immediately to the DSL.

5.0 StopSO and the Member

The therapeutic process is delivered to clients by members. StopSO itself does not deliver any therapeutic services to clients.

An ongoing therapeutic process may lead to the therapist identifying safeguarding concerns. The therapist can raise safeguarding concerns with the StopSO DSL at any time, either to seek advice and support, or to information share.

However, the member will also have duties and responsibilities arising from their own position. The member will have their own professional regulation position to consider. They may have contractual obligations to consider, either towards their clients or towards an employer or other umbrella organisation. They should have their own safeguarding policy and procedures to consider. Each member will have different circumstances and considerations.

The member must be familiar with any other safeguarding policy and procedure applicable to themselves and their practice. The member will likely benefit from seeking professional support and guidance from their supervisor and their regulating body. This safeguarding policy is not an alternative to those other policies and procedures.

StopSO supports its people and its members in safeguarding best practice through this policy and the DSL will always be willing to help. Sometimes the best help will be to signpost the member to another safeguarding support point, but this will never be a route to absolve StopSO of its safeguarding responsibilities.

The StopSO DSL will always help and support a member with safeguarding concerns. The StopSO DSL, chair and board will always respect the views of the member and will always strive to reach consensus as to what if any safeguarding steps are necessary. The views of the member would always be a very important factor in the decision-making process. However, members must be aware that the StopSO DSL, chair and board may have a duty under this policy to take necessary safeguarding steps directly if required, even if that decision is at odds with the views of the member. StopSO does not envisage that this scenario will arise often if at all, not least because reports to the DSL from members will most often be done on a confidential (thus usually anonymous) basis in the first instance in accordance with this policy. Anonymisation will be secured by the use of the ‘SS’ number not by name.

6.0 Safeguarding Steps

There is no exhaustive list of the steps or measures that StopSO might take to effectively safeguard. It is about identifying the concerns, reporting those concerns to others where necessary, initiating enquires where necessary, using prevention or early help to address emerging concerns, immediate protection when necessary, and securing care or support.

StopSO acknowledges that consideration of making disclosures to the police or local authority will be an important and necessary safeguarding step in appropriate circumstances. However, safeguarding effectively is a much wider topic.

StopSO also acknowledges that supporting a client in a sustainable therapeutic process might itself be a very important safeguarding step. The very purpose of StopSO includes preventing harm through therapy.

It can be useful to think of 5 Rs:

Recognise – understand the signs and symptoms of potential abuse, harm and neglect. Listening actively and reading carefully are important safeguarding steps. Sometimes being a good listener is itself an effective safeguarding Being non-judgemental, curious, and avoiding stereotypes or assumptions really helps. Safeguarding training helps. Recognising may come through disclosures made during the referral process or therapeutic process. These may be ‘red flags’ or they may be more subtle. If it doesn’t feel right – do something.
Respond – If you have a concern, it is essential you respond appropriately and do not ignore the situation. Sometimes talking to the person/client about your concerns is Encouraging the person to get effective support, following up on concerns, checking in, ensuring there is a next point of contact, being proactive. Sometimes it is about creating a safe place in the future to ensure you recognise the signs. Signposting and encouraging voluntary referral to other agencies can make a real difference. Even acknowledging that something is not OK might be important.
Report – Report to supervisor, a DSL, or other appropriate support Confidentiality is important, so only share what is necessary with those in the safeguarding process, but privacy and confidentiality need never prevent effective safeguarding when necessary. discussing a situation with a supervisor or DSL will be an important safeguarding step when appropriate. Sense-checking is often best done with another. This is part of the reason StopSO operates with multiple DSL’s. Maintain confidentiality whenever possible by having anonymised communication.
Record – the who, what, why, when and where of safeguarding. Take contemporaneous, comprehensive notes and Making good quality, legible, contemporaneous notes is itself an important safeguarding step. This makes it more likely that the bigger picture can be seen and less likely that opportunities to safeguard are not missed. This record keeping should include what you have recognised, how you have responded, what if anything has been reported (and justifications for not reporting if that is the decision), as well as in respect of any referrals made.
Refer – This may be the responsibility of the DSL or of the member, but if the necessary action is to tell the police or the local authority then it must be This often means making a disclosure to a third party, whether a person or organisation. Referring might be to a protective agency such as the police or the local authority, but it might also be to a supportive agency such as another charity or support service, to medical or mental health services, in respect of housing, outreach, drug and alcohol services and so on.

7.0 What should a Member do with a safeguarding concern

If a safeguarding concern is detected by the member in the process of individual therapy (and it is not a risk of serious harm that is imminent – see relevant section) the member should consider what if any safeguarding mitigation steps might be available. Always do something, never ignore.

A discussion with a supervisor will usually be helpful. Consideration of guidance from a regulating body might assist.

Contacting a StopSO DSL might be useful.

Disclosure of the safeguarding concern to a public authority is only one potential safeguarding mitigation step.

8.0 What should a StopSO person do with a safeguarding concern

If a safeguarding concern is detected by a StopSO person, the concern should be reported forthwith to the DSL. Always do something, never ignore.

Safeguarding concerns identified by a StopSO person in respect of a new referral that has not yet been referred to a therapist will be considered by the DSL before the client is referred to a therapist, if this is to be done at all.

9.0 Confidentiality

The information held by StopSO or the member will often be private and confidential.

THIS DOES NOT MEAN YOU CANNOT SHARE A SERIOUS SAFEGUARDING CONCERN.

However, privacy and confidentiality are very important and must be respected whenever it is possible to do so in a way that is consistent with safeguarding.

The main legal sources for the control of privacy and confidentiality in this area can be found in:

Common Law duty of
Human Rights Act
Data Protection Act 1998 and General Data Protection Regulation

Although some scenarios may require a more detailed consideration of these and other statutory provisions, the key message of this policy is that the law does not prevent the sharing of information when it is necessary and proportionate so as to address a serious safeguarding concern.

The starting point is the personal data and information, especially sensitive personal data, is to be kept private and confidential.

In the context of this policy, this means that reports and discussions about safeguarding should be anonymised wherever possible and consistent with the safeguarding concern raised. Everyone involved should be mindful of jigsaw identification, take a need-to-know approach.

A client can always give consent to share their own otherwise private data. Safeguarding concerns will sometimes be so serious that a client’s consent is immaterial to a decision to share information. Consent to share should never be sought if a disclosure will be made in any event.

In other cases, it will be appropriate or necessary to seek a client’s consent to share information. Many effective safeguarding steps can be discussed with a client and consent to share personal data will be necessary and appropriate.

There should never be a promise to keep information private and confidential if that promise cannot be kept.

10.0 Seriousness and Imminency of Risk

If a StopSO person or member becomes aware of a risk of serious harm to a person and that risk is deemed imminent then immediate disclosure to the police and or social services must be considered. If other contact details are not available, call 101 to report the concerns.

This policy deliberately does not define either ‘serious harm’ or ‘imminent’. For the purpose of this policy, each case must be considered on its own facts. However, a risk that a person will be a direct victim of a sexual offence will almost inevitably mean that they are at risk of serious harm. That risk will be imminent if the serious harm may arise before any other safeguarding measure is likely to be effective. Assessing risk, seriousness and imminency is a matter of judgement, using the best information available.

In most cases, even some urgent cases, passing information to the DSL and seeking advice and guidance will be appropriate before making a decision as to what, if any, safeguarding measure is appropriate.

StopSO cannot mandate what action a member is to take when considering safeguarding.

11.0 Record Keeping

Keeping good quality records of information is an important safeguarding principle.

Good quality record keeping helps keep people safe:

It helps build a picture.
It improves accuracy and timeliness.
It helps avoid missing

Handwritten notes must be legible and as contemporaneous as possible. If making the notes contemporaneously is impossible then they should be made as soon as possible afterwards. Notes, records or log entries should be dated and timed.

Notes and Records should be:

Factual
Using the person’s own words where possible
A record of what you saw and heard
Contemporaneous

The DSLs will store notes and records of safeguarding concerns on the shared drive facility anonymised. Notes of any meetings of members/DSL’s to be stored similarly to marry up with the client file as managed by the referral process.

Members must have a policy regarding storage of safeguarding concerns. Given the range of arrangements of individual members this policy does not specify a storage and retention method for members. It is best practice to store anonymised copies of notes and records in a separate safeguarding file or folder, as well as on or with client files.

If information is being received that a person is a victim of any abuse, including in particular if they are a victim of sexual abuse, good quality record keeping is very important, and itself be an important safeguarding step. This is especially so if the person making the disclosure is a child or vulnerable adult. At the earliest opportunity, a careful record must be completed by the therapist/safeguarding lead and the following need to be clearly described:

what the informant has said using their own words where
how if at all the StopSO person or member has
any discussions with the DSL, supervisor, other third party or agency.
any relevant information about the informant’s physical or mental appearance or behaviour.

An initial account to a therapist that a person has been the victim of abuse can provide important evidence in a court case, in both criminal and family proceedings. If a person has produced documentation, such as drawings or the written word, this should be retained by the therapist

Notes that are not ‘contemporaneous’ i.e. made within hours of an incident, may be less accurate, or impacted by events, memory, or interactions with others. Consequently, those notes or records may be less reliable and thus less useful. This may mean the records are of less evidential weight or that any inaccuracy negatively impacts the discloser of the information. A failure to keep good quality records it itself a safeguarding risk.

12.0 Designated Safeguarding Leads

StopSO will operate with 3 DSL’s, to ensure that sufficient safeguarding support is always available to the charity and to its members.

The current DSLs are:

John Goss [email protected]
Emma Barwell [email protected]
Sue Maxwell [email protected]

Any StopSO person or member can contact any DSL at any time, directly, or by emailing.

This is to be done via [email protected] which is accessed by 2 people able to process the concern/query.

It is the responsibility of the DSL’s individually and collectively, along with the chair, to ensure that there is an effective system in place to cover periods of absence, leave, illness or other unavailability.

The DSL receiving the safeguarding information will be able to consider the contents of concern, and share with each other the possible actions, advice or guidance. They, as appointed DSLs by the board and chair, will make the decisions as the role requires.

Generally, if positive action is being considered by StopSO itself, all three leads, or as many are at that time available, will seek to agree on the action going forward. The chair of the board of trustees may be included in discussions where appropriate but not as a matter of course. Board meeting feedback requires a statement as to how many, if any cases are being considered, and any procedural issues that may have arisen.

If, exceptionally, none of the DSLs are available, the chair or other StopSO person may temporarily delegate the role of the DSL to another trustee.

The DSL should prepare an annual report for the board as to the effectiveness of this policy, including any recommendations for learning or development. This is a procedural process review and will not involve discussions about individual cases.

13.0 Therapy to Children

Some StopSO members, who are appropriately qualified and trained may delivery therapeutic services directly to children. This is highly valuable and important work.

Child therapy services give rise to particular safeguarding issues, although the overarching policy and procedures are the same. Particular regard should be had to the Child Protection Policy.

StopSO members working with children will ensure they have effective procedures in respect of:

Having appropriate and sufficient
Having appropriate and timely risk assessments ongoing throughout the work
Responding compassionately and appropriately to complaints and allegations of
Having adequate insurance cover for any activity with children and young
Regularly reviewing, monitoring and, where appropriate, updating these procedures where appropriate.

When working with children, consent from the parent/guardian is required to commence any therapeutic work or assessment.

14.0 Particular Safeguarding Scenarios

It is unhelpful to try to plan specifically for every scenario. Effective safeguarding requires understanding of principles and procedures. It is the experience of StopSO that some categories of concern arise more frequently. Therefore, these scenarios are discussed in the policy. However, this does not mean that other scenarios are not important safeguarding issues.

Particular attention should be given to the section on seriousness and imminency of risk:

Every concern is valid – if it doesn’t feel right, do something.

15.0 Responding to information that a client has been a victim of abuse

Many clients who work with StopSO therapists have been victims of sexual, physical or psychological abuse. This need not be a safeguarding concern of itself. However, if a client is presenting as being in imminent danger of serious harm from new or further abuse, safeguarding concerns will certainly arise. Even relatively minor incidents may be serious if properly understood in their context.

If this scenario arises at the point of StopSO receiving a referral request, the StopSO person should refer the matter to the DSL process immediately. Consideration will be given to urgent safeguarding steps, including where appropriate reporting the matter to the police or local authority. Communication with the referral will be considered although often no promise of confidentiality can be offered.

If this scenario arises during the therapeutic process the member must follow their own safeguarding policy and any other relevant safeguarding policy, including this policy. They may seek advice and support from any or all of; their supervisor, the StopSO DSL, regulating body, legal advice, insurer.

In any event, an allegation of abuse or neglect may lead to a criminal investigation so nothing must be done which may jeopardise a police investigation, such as asking leading questions or attempting to investigate the allegations. Good quality note and record keeping is especially important. Do not promise confidentiality if you cannot keep that promise.

16.0 Responding to information that a client presents a risk of harm to another person

Many StopSO clients present as having engaged in harmful, risky or illegal thought or behaviour. These scenarios are likely to give rise to safeguarding concerns at some level, and will require consideration of what, if any safeguarding steps are necessary.

An imminent risk of serious harm will require consideration of disclosure to the police or the local authority.

If this scenario arises at the point of StopSO receiving a referral request, the StopSO person may refer the matter to the DSL process immediately. Consideration will be given to urgent safeguarding steps, including where appropriate reporting the matter to the police or local authority.

If this scenario arises during the therapeutic process the member must follow their own safeguarding policy and any other relevant safeguarding policy, including this policy. They may seek advice and support from any of; their supervisor, the StopSO DSL, regulating body, legal advice, insurer.

17.0 Responding to information that a person is under police investigation for sexual offending

StopSO members support many individuals who are under police investigation. The fact that a client has committed or is alleged to have committed a sexual offence is not necessarily of itself a safeguarding concern.

In such cases the StopSO member should be especially alive to any safeguarding concerns that might arise in the context of the Criminal Justice Process. Examples include: the risk of self-harm or suicide (especially at key milestones), the need to safeguard others in the event the client is incarcerated, the risk to others if a client presents in breach of bail conditions or protective orders, the risks of homelessness, the risks associated with substance misuse, and the risks of further offending.

The fact that a person is accused of committing a sexual offence is a relevant factor when considering safeguarding, but it is especially important not to make assumptions. Some clients will be innocent of the accusations but will still be seeking therapeutic support. Some clients will be innocent of the accusations but will have committed other offences. Some clients will have committed the offences alleged.

Being under police investigation or subject to protective orders can be a very important protective factor.

Information that a client is continuing to offend raises very important safeguarding concerns. If this information comes to a StopSO person they must immediately report the information to the DSL. If this information comes to a member this policy gives the strongest possible encouragement to the member to discuss the matter immediately with a supervisor and otherwise follow any relevant safeguarding policy and guidelines, including this policy.

Online offending is no less serious than offline offending and seeking to distinguish between online and contact offending is not considered helpful.

Distinguishing cases on the basis of whether there is an identifiable, known victim is not considered helpful.

Each case must be considered on its own facts and circumstances.

18.0 Responding to information that a client is at risk of self-harm or suicide

Unfortunately, many StopSO referrals and many clients of members present in significant crises. Indeed, much of the work of StopSO and its members might be about managing suicidal thoughts and conversations. When this situation arises, safeguarding concerns arise, both for the client and for other connected persons, and sometimes for others.

A StopSO person must be alive to these concerns and pass information to a supervisor and/or the DSL accordingly. The DSL is in a better position to assess the information, investigate where appropriate and decide what if any safeguarding steps may be required.

If this scenario arises during the therapeutic process the member must follow their own safeguarding policy and any other relevant safeguarding policy, including this policy. They may seek advice and support from any of; their supervisor, the StopSO DSL, regulating body, legal advice, insurer.

Members should keep to hand an update to list of contacts and referrals in respect of self-harm and suicide. This may include the Samaritans (116 123), but may also include particular services, charities or other support points known to the member locally or nationally. If any StopSO member should need help with this list, they should speak to their supervisor.

19.0 Making a disclosure to the Police or Local Authority

Sometime the necessary safeguarding step is to make a referral to the police or local authority.

Whether such a referral should be made to the police, the local authority or other statutory agency is a matter of judgement for the member, their supervisor, and/or the DSL. Common sense must prevail as to which agency and by what method.

Reports to the police will usually be made by:

Calling 101 and providing information over the phone
Call 999 in cases where there is a danger to life or where criminal conduct is likely to be serious and in progress
Contacting the Officer in the Case of an existing investigation

Reports to the Local Authority will usually be to the social care team at the local authority where the victim is currently living.

However the report is made, a good quality record should be kept of what was reported, when and by whom. Online referrals should be followed up if not acknowledged, usually within 24 hours or sooner depending on the circumstances.

20.0 Making a disclosure to another third party

Some safeguarding steps involve making disclosures to other third parties. This policy does not attempt to be exhaustive or prescriptive about who can be told what or when, because each case requires its own consideration. Examples might include: making a disclosure to another professional, such as a doctor or a lawyer. It might involve disclosure to a family member or friend. It might involve disclosure during a muti-agency working arrangement.

In any event, the principles of safeguarding as outlined in this policy continue to apply, especially regarding confidentiality, record keeping and timeliness.

21.0 Supervision

Supervision is an important part of effective safeguarding. All aspects of safeguarding should be discussed with the supervisor, to help keep emotive issues raised in perspective and to provide support and guidance.

Monthly supervision is required for all therapist members with a StopSO supervisor, based on the number of clinical hours undertaken.

If a therapist does not receive sufficient referrals to warrant a specialist supervisor, attendance at the StopSO peer supervision groups is encouraged. Supervisors also offer an ad hoc arrangement to encourage a flexible approach to professional guidance and support. The supervision sessions should be based on an agreed structure that should include: formative aspects (developing the therapist), restorative aspects (helping them deal with the personal impact of the work), and normative aspects (ensuring that they are working to agreed standards).

22.0 Disclosure and Barring Service checks

All therapists, volunteers and trustees working with child abuse, are responsible for their own DBS checks.

Enhanced checks are for anyone engaging in regular activity which involves caring for, training, supervising or being in sole charge of vulnerable groups.

Enhanced checks contain the same information as standard checks but with the addition of a check on the barred lists if requested and any locally held police force information considered relevant to the job role, by chief police officers.

23.0 Legal Guidance

StopSO DSL’s, Trustees and all members have free access to legal guidance from solicitors. This should be sought at any point to clarify expectations and to receive measured advice regarding legal and ethical considerations:

This is provided by: Stone King Solicitors

Contact: [email protected] or Matthew Graham ([email protected] 07779 227261)

A member may also benefit from support through their insurer or regulator, and should be familiar with the routes to access advice and support.

Each member is encouraged to keep a central record of contact numbers and email addresses for support points, including those in this policy.

Safeguarding decisions never have to be taken alone but are sometimes very urgent.

Know who you will call if you need to.

Appendix 1 – StopSO safeguarding flowchart

Appendix 2 – Important But not Safeguarding Policy

Working jointly with other agencies

The sharing of information amongst practitioners working with children and young people is essential as it is when working with adults who are victims, family members or perpetrators. In many cases it is only when information from a range of sources is put together that a child can be seen to be in need or at risk of harm, or the scale of any risk of causing harm can be assessed acurately. Remember that most child deaths during the past three decades have been related to the failure of agencies to work together and share information. It is the policy of this organisation that therapists should share information and assist in assessments with statutory authorities.

Therapists are likely to be involved with statutory agencies in three main ways:

Referring concerns to social services or the police
They may be approached by social services and asked to provide information or to be involved in an assessment
They may be asked to provide help or a specific service as part of an agreed plan and to contribute to reviewing